Since September 6, 2006, the Environmental Protection Agency (EPA) and the Department of Transportation (DOT) have required that Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) of hazardous waste use the uniform hazardous waste manifest (paper manifest for the purposes of this article) to document off-site transportation. The paper manifest is a single page document (a continuation page is available for more than four entries), with regulations requiring six copies.
This changed when DOT launched the Electronic Manifest System (e-Manifest) on June 30, 2018. This change updated hazwaste tracking with modern technology to increase accuracy while saving significant amounts of time and money. Below are answers to questions that you might have about this transition.
Can I still use paper manifests?
You may still use the paper manifest after June 30. The EPA is encouraging (but not requiring) generators to use up their supplies of 6-copy paper manifests and switch over to a new 5-copy version that will be available by June 30 from the EPA’s registered printers. The only requirement regards copy 1 of the 6-copy version: After June 30, a generator must apply a pre-printed adhesive label reading “Designated facility to EPA’s e-Manifest system” over existing text reading “Designated facility to destination State (if required).”
Beginning June 30, 2021, designated facilities will be restricted from mailing paper forms of the manifest to EPA for uploading into the e-Manifest System. After several years, EPA will evaluate the use of the e-Manifest System and determine whether to further restrict the use of paper manifests. This will not affect paper manifest users for at least five years from the launch date.X
How do I switch from paper to electronic?
A generator that wants to start using the e-Manifest System must first ensure participation by its initial transporter and the designated facility. After ensuring the participation of all waste handlers “cradle-to-grave,” the generator must ensure that any employee who will create, view, sign and/or make corrections to the e-Manifest is registered and has created an individual account with RCRAInfo. Afterward, the generator may begin using the e-Manifest System for any waste shipment subject to manifesting by Federal or state regulations.
What will this cost?
One unavoidable feature of the new rule is the fee to be collected to fund the e-Manifest System. The fee will be paid by the designated facility – and no doubt passed on to the generator – and is determined by participation in the e-Manifest System:
- $4.00 for an electronic manifest (including a hybrid manifest)
- $7.00 for a data file upload of paper manifest data
- $13.00 for an upload of paper manifest image
- $20.00 for a submission of a paper manifest form by mailX
Do e-Manifests meet both Federal and state requirements?
Fortunately, all requirements of Federal and state regulations for the use of the paper manifest will be met by use of the e-Manifest System. These requirements include but are not limited to:
- State-specific hazardous waste codes. You will find these ready to use within the e-Manifest System.
- State requirements for paper manifests. If a state requires the generator to submit a copy of the paper manifest, it may continue to do so after June 30 and for as long as the generator continues to use the paper manifest in lieu of the e-Manifest System. However, once a generator begins use of the e-Manifest System, a state must be satisfied with its access to data in the e-Manifest System and can no longer request a paper copy of the manifest from the generator.
- State and Federal requirements that the generator complete the exception report.
- State-specific requirements that the designated facility submit paper copies to destination state, generator state, generator and transporter.
- Corrections to manifests. Any registered person may make corrections within the e-Manifest System after the designated facility has submitted its copy.
The rule implementing the e-Manifest System makes it immediately effective nationwide. All states – even those with an authorized hazardous waste program – have no choice but to comply with its requirements.
Unfortunately, the DOT is not a participant in the e-Manifest System and will continue to require the transporter to maintain the manifest in some paper form. This can be accomplished in one of two ways:
- If neither the generator, transporter nor designated facility uses the e-Manifest System, the transporter maintains copies 1-5 of the paper manifest until reaching the designated facility. Then the transporter must enter information into the e-manifest system and destroy the paper copies.
- The generator prints a paper copy of the e-Manifest after completing it. Both generator and transporter sign electronically. The transporter maintains this copy until reaching the designated facility and destroys it there.
So what should I do now?
- Use up your stocks of the 6-copy paper manifest and prepare to use either the 5-copy version (if still using paper manifests after June 30) or the modified 6-copy version described above.
- Learn more about the e-Manifest System here:
EPA’s e-Manifest testing website
EPA’s e-Manifest website
EPA’s e-Manifest ListServ (send a blank message to: eManifestemail@example.com)
- Register and create an account in RCRAInfo for yourself and any employee who intends to use the e-Manifest System.
- Contact the transporter(s) and designated facility for your hazardous waste shipments to determine their participation. They may have their own equipment for accessing the e-Manifest System, and you may need to be trained in its use.
Whether you welcome or dread this change from paper to electronic, or fall somewhere in between, it’s on its way, and we can all hope for the benefits highlighted by the EPA. The agency is looking to the new System to increase compliance, make data more accurate, timely and accessible, and annually save state and industry users 300,000-700,000 hours of labor and $75-$90 million in costs.